MHA Monday Report June 2, 2025

MHA and DataGen to Host Upcoming Medicare Quality-Based Program Webinars

The MHA has partnered with DataGen to host two upcoming webinars focused on the Medicare fee-for-service (FFS) quality-based programs which can reduce hospital inpatient FFS payments by up to 6% based on performance. The webinars …


MHA Releases Executive Summary of Recent MDHHS Blood Lead Testing Mandate Rules

The MHA recently released an executive summary regarding the Michigan Department of Health and Human Services’ (MDHHS) adoption of new administrative rules establishing universal blood lead testing requirements for minors across the state. The goal of …


CMS Issues New Guidance on Hospital Price Transparency Requirements

The Centers for Medicare & Medicaid Services (CMS) released updated guidance May 22 related to hospital price transparency requirements under Executive Order 14221, “Making America Healthy Again by Empowering Patients with Clear, Accurate and Actionable …


Language, Trust and Care: Reflections from the AHA Behavioral Health Workshop

I had the opportunity to attend at the end of April a Behavioral Health Workshop in New Orleans hosted by the American Hospital Association. This interactive event brought together hospital leaders, clinical teams and behavioral health professionals to co-design care


Keckley Report

The Summer of 2025 for U.S. Healthcare: What Organizations should Expect

“Last Thursday, the Make America Healthy Again Commission released its 68-page report “Making America’s Children Healthy Again Assessment” featuring familiar themes—the inadequacy of attention to chronic disease by the health system, the “over-medicalization” of patient care vis a vis prescription medicines et al, the contamination of the food-supply by harmful ingredients, and more. HHS Secretary Kennedy, EPA Administrator Zeldin and Agriculture Secretary Rollins pledged war on the corporate healthcare system ‘that has failed the public’ and an all-of-government approach to remedies for burgeoning chronic care needs. …

As MAHA promotes its agenda, Congress passes a budget and MAGA advances its anti-establishment agenda vis a vis DOGE et al, healthcare operators will be in limbo. The dust will settle somewhat this summer, but longer-term bets will be modified for most organizations as compliance risks change, state responsibilities expand, capital markets react and Campaign 2026 unfolds.

And in most households, concern about the affordability of medical care will elevate as federal and state funding cuts force higher out of pocket costs on consumers and demand for lower prices.

The summer will be busy for everyone in healthcare.”

Paul Keckley, May 27, 2025


Laura AppelMHA in the News

WLUC TV6 in Michigan’s Upper Peninsula published a story May 29 on the shortage of inpatient psychiatric beds in Michigan, placing a heavy focus on the testimony the MHA delivered May 20 before the House …

MHA and DataGen to Host Upcoming Medicare Quality-Based Program Webinars

The MHA has partnered with DataGen to host two upcoming webinars focused on the Medicare fee-for-service (FFS) quality-based programs which can reduce hospital inpatient FFS payments by up to 6% based on performance. The webinars are free to attend, but registration is required.

DataGen Overview of Medicare’s Value-Based Purchasing Program & Analyses for MHA

This session, scheduled for 1:30 p.m. June 11, will review the Medicare value-based purchasing program, which evaluates hospital performance on measures across four domains. The CMS withholds 2% from Medicare FFS inpatient claims, totaling approximately $1.7 billion nationally, and redistributes these funds based on performance.

DataGen Overview of Medicare’s RRP/HAC Programs & Analyses for MHA

This session, scheduled for 1:30 p.m. June 17, will review the Medicare readmissions reduction (RRP) and hospital acquired conditions (HAC) reduction programs. The RRP evaluates readmissions for six medical conditions, with hospitals subject to penalties of up to 3% on Medicare inpatient payments for all FFS discharges. The HAC program assesses hospital performance using Medicare claims and Centers for Disease Control measures and imposes a 1% payment reduction to Medicare FFS payments for 25% of hospitals nationally.

Hospital quality department and finance staff are encouraged to register. The webinars will be recorded and available for future reference. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report April 28, 2025

MHA Testifies on Nurse Licensure Compact Bills, Senate Passes Prescription Drug Affordability Board and Momnibus Legislation

The House Health Policy heard testimony from the MHA in support of creating a nurse licensure compact and the Senate voted to establish a Prescription Drug Affordability Board in the state of Michigan during the …


GME Capitol Day Approaches May 21

The MHA is hosting the 2025 MHA Graduate Medical Education (GME) Capitol Day from 9 a.m. to 3:30 p.m. May 21 in Lansing. The event is an opportunity for Michigan’s physician residents from teaching hospitals and academic …


CMS Releases FY 2026 Proposed Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for fiscal year (FY) 2026. Key provisions of the proposed rule include: Increasing the …


MHA Unemployment Compensation Program Receives Award for Outstanding Performance

The MHA Unemployment Compensation Program (UCP) was recognized by the National Association of State Workforce Agencies (NASWA) April 24 for the MHA UCP’s commitment to utilizing the NASWA’s nationwide, web-based system SIDES for receiving new claims and responding to …


CMS Releases FY 2026 Proposed Rule for Skilled Nursing Facilities

The CMS recently released a proposed rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities for fiscal year (FY) 2026. Key provisions of the proposed rule include: Increasing the per-diem …


Celebrate Patient Experience Week with Upcoming Webinars

The MHA is offering ways for hospital staff to engage during Patient Experience Week (April 28-May 2), to support and amplify patient-centered care. The upcoming Patient and Family Engagement Improvement Sprint webinar series, hosted …


CMS Releases FY 2026 Proposed Rule for Inpatient Rehabilitation Facilities

The CMS recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year (FY) 2026. Key provisions of the proposed rule include: Increasing the …


MHA Virtual Member Forum Focuses on Cyberattack Response

The MHA, in conjunction with its statewide Health Information Technology Strategy Committee, is hosting a cybersecurity and cyberattack response virtual member forum from 9:30 to 11 a.m. May 9. This free, members-only event features six …


The Power of Patient-Centered Care

It’s no secret that patient experience within hospitals and health systems has evolved over the years – especially following the COVID-19 pandemic. With Patient Experience Week (PX Week) around the corner, it’s a good time to recognize the …


Keckley Report

Tax Exempt Status for Not-for-Profit Hospitals: The Debate Ahead

“Tax exemptions for hospitals are not a new topic inside healthcare, but lately they’ve drawn outside attention from regulators and in media. They seem to be asking ‘Do not-for-profit hospitals deserve their tax breaks?’ …

Hospitals face a headwind, especially those that are tax-exempt. Every U.S. hospital is reeling from the uncertainty surrounding the Kennedy (HHS)-Oz (CMS)-Makary (FDA) trifecta that will regulate hospital affairs in the next few months. Every hospital is feeling heat from disgruntled physicians and worn-out frontline caregivers. Every hospital is worried about how tariffs will impact supply chain costs and all are taking a cautious approach to major capital projects. And all face increased pushback from state legislators who think price controls on hospitals might be the answer.

For Rick Pollack and team at the American Hospital Association, it’s not business as usual. The hospital big tent is under duress. And NFP tax exempt hospitals might be where it’s hottest. Large employers have targeted large NFP systems for cost reduction and Congress appears poised to impose restrictions on NFPs intended to rein-in what some consider excesses under the protection of tax-exempt status. …

Spending in healthcare at current levels is not sustainable. NFP system say the health of the communities they serve is their highest priority, though many limit their attention to lucrative services while neglecting others that might pay longer-term dividends in public health.

Utopian? Yes, but necessary. Actions not taken by NFP systems to demonstrate they deserve their tax exemptions is risky. And lack of will to adopt minimal standards will ultimately mean exemptions are linked to charity-care only.

In 2025 and beyond, tax exemptions for not-for-profit hospitals will garner attention. They’re not guaranteed and they’re under attack.”

Paul Keckley, April 21, 2025


New to KnowNews to Know

  • The MHA is issuing a request for proposal for a $2.5 million competitive grant program for Michigan healthcare entities to expand access to hospital-based peer recovery coach services.
  • Registration is now open for the MHA Annual Membership Meeting June 25 through 27 at the Grand Hotel on Mackinac Island. Members are encouraged to register by May 23 to attend this memorable event

Jim Lee speaks with Mid-Michigan NOW about AI.

MHA in the News

Jim Lee, senior vice president, data policy & analytics, MHA, appeared in a story about artificial intelligence (AI) in healthcare aired by Mid-Michigan NOW on April 23. Lee discussed how AI is being used by …

CMS Releases FY 2026 Proposed Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for fiscal year (FY) 2026.

Key provisions of the proposed rule include:

  • Increasing the IPF PPS federal per diem base rate by a net 1.8% after all adjustments, from $876.53 to $891.99. IPFs that fail to comply with the CMS IPF Quality Reporting Program (QRP) requirements would be paid using a base rate of $874.57.
  • Increasing the Electroconvulsive Therapy payment per treatment by a net 1.8% from $661.52 to $673.19 for IPFs that comply with IPF QRP requirements and $660.04 for IPFs that fail to report data.
  • Increasing the labor-related share from the current 78.8% to 78.9%.
  • Increasing the cost outlier threshold by 3.3% from the current $38,110 to $39,360 to achieve the 2% target for outlier payments as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
  • Revising facility-level adjustment factors:
    • Rural adjustment from 1.17 to 1.18
    • Teaching adjustment from 0.5150 to 0.7981
  • Updating the IPF QRP to:
    • Remove four measures beginning with the calendar year 2024 reporting period and or FY 2026 payment determination:
      • Facility Commitment to Health Equity.
      • COVID-19 Vaccination Coverage among Health Care Personnel.
      • Screening for Social Drivers of Health.
      • Screen Positive Rate for Social Drivers of Health.
    • Modify the reporting period of the 30-day-Risk-Standardized All Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge measure (referred to as the IPF ED Visit measure) from a one year, calendar year to a two-year, fiscal year period.
  • Seeking feedback on three topics through requests for information for:
    • A potential future star ratings system for IPFs.
    • Future measures for the IPF QRP.
    • Using the Fast Healthcare Interoperability Resources standard for electronic exchange of healthcare information for patient assessment reporting.

The CMS is seeking comments on opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program.

The MHA will provide IPFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by June 10 and to contact Vickie Kunz at the MHA with questions and  issues identified by May 27.

CMS Releases FY 2026 Proposed Rule for Inpatient Rehabilitation Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2026.

Key provisions of the proposed rule include:

  • Increasing the IRF PPS payment rate by a net 2.4% after all adjustments, from $18,907 to $19,364. IRFs that fail to comply with the CMS IRF Quality Reporting Program (QRP) requirements are subject to a two-percentage point reduction.
  • Increasing the labor-related share from the current 74.4% to 74.5%.
  • Decreasing the cost outlier threshold by 0.6% from the current $12,043 to $11,971 to achieve the 3% target for outlier payments as compared to aggregate IRF payments, decreasing the number of cases that qualify for outlier payments.
  • Changes to the IRF QRP that propose to:
    • Make optional the reporting of four standardized patient assessment data elements in the IRF Patient Assessment Instrument focused on social determinants of health beginning with Oct. 1, 2025 reporting. The items would be removed entirely by the FY 2028 IRF QRP.
    • Remove two COVID-19 vaccination measures from the IRF QRP for FY 2026.
    • Seek input on future IRF QRP measure concepts, reducing the burden of reporting patient assessment data and advancing digital quality measures in the IRF QRP.

The CMS is seeking comments on opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program.

The MHA will provide IRFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by June 10 and to contact Vickie Kunz at the MHA with questions and  issues identified by May 27.

CMS Releases FY 2026 Proposed Rule for Skilled Nursing Facilities

The  Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities (SNFs) for fiscal year (FY) 2026.

Key provisions of the proposed rule include:

  • Increasing the per-diem federal rate by a net 3% after the market basket update, productivity adjustment and other adjustments. SNFs that fail to satisfy Quality Reporting Program requirements will be subject to a 2-percentage point reduction.
  • Updating the labor-related share of the per diem rate from 72% to 71.9%.
  • Making technical changes to the Patient-Driven Payment Model ICD-10 code mapping that assigns patients to clinical categories.
  • Removing items recently adopted as standardized patient assessment data elements under the social determinants of health category.
  • Issuing three Requests for Information regarding future measure concepts, potential revisions to submission deadlines for assessment data collected and advancing digital quality measurement.
  • Removing the health equity adjustment from the SNF Value-Based Purchasing program.

The CMS is seeking comments on opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by June 10 and to contact Vickie Kunz at the MHA with questions and issues identified by May 27.

CMS Releases FY 2026 LTCH Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2026.

Specifically, the rule proposes to:

  • Increase the standard LTCH PPS rate by a net 2.7%, after the 0.8% productivity adjustment and budget neutrality adjustment,s from $49,383 to $50,729, for LTCHs that meet the CMS quality program reporting requirements. LTCHs that fail to meet these requirements are subject to a two percentage point reduction to the annual update.
  • Continue paying cases at the site neutral rate if they fail to meet LTCH criteria.
  • Increase the high-cost outlier (HCO) threshold by 18% for standard LTCH cases from the current $77,048 to $91,247, to achieve the target of paying roughly 8% of aggregate LTCH payments as HCO payments.
  • Use the inpatient PPS cost outlier threshold proposed at $44,205 for site-neutral cases.
  • Update the LTCH Quality Reporting Program by removing four standardized patient assessment data elements focused on social determinants of health and modifying the COVID-19 vaccine among patients and residents measure to exclude patients who expire.
  • Seek input through a Request for Information on opportunities to streamline regulations and reduce administrative burdens on providers, suppliers, beneficiaries and other interested parties participating in the Medicare program. Members may submit comments to the CMS.:

The MHA continues to review the proposed rule and will provide LTCHs with an estimated impact analysis in the next few weeks. The MHA encourages hospitals to review the proposed rule and submit comments to the CMS  by June 10 and to notify Vickie Kunz at the MHA regarding questions or issues identified by May 27.

CMS Releases FY 2026 Hospital IPPS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service inpatient prospective payment system (IPPS) for fiscal year (FY) 2026.

The rule proposes to:

  • Increase the standard operating rate by a net 3.2%, after the 0.8% productivity cut and budget neutrality adjustments, from $6,624.39 to $6,835.47, for hospitals that successfully comply with the CMS quality reporting program and electronic health record requirements. Hospitals that do not meet the requirements for these programs are subject to a reduced annual update.
  • Increase the federal capital rate by 3.3%, from $512.14 to $528.95.
  • Decrease the cost outlier threshold by 4.1%, from $46,217 to $44,305, to maintain the target of paying 5.1% of aggregate IPPS payments as outlier.
  • Rebase and revise the labor-related share of the standardized operating rate from 67.6% to 66% for hospitals with a wage index greater than 1.0.
  • Increase disproportionate share hospital and uncompensated care (UCC) payments by $1.5 billion nationally. UCC payments will be allocated using the average of three most recent years of audited Worksheet S-10 data.
  • Add seven new Medicare-Severity (MS) Diagnosis Related Groups, while deleting six MS-DRGs, with most changes within Major Diagnostic Category 05, Diseases and Disorders of the Circulatory System.
  • Remove four measures from the Hospital Inpatient Quality Reporting Program, effective with the 2024 reporting and FY 2026 payment period:
    • COVID-19 vaccination coverage among health care personnel.
    • Hospital commitment to health equity structural measure.
    • Screening for social drivers of health.
    • Screen positive rate for social drivers of health.
  • Modify the Hybrid hospital-wide readmission and mortality measures and the stroke mortality and elective total hip and knee arthroplasty measures.
  • Update and codify the Extraordinary Circumstances Exception (ECE) policy to clarify that the CMS has discretion to grant an extension in response to an ECE request from a hospital.
  • Remove the health equity adjustment from the hospital value-based purchasing program scoring methodology beginning with the FY 2026 program.
  • Include Medicare Advantage patients in the calculation of multiple claims-based measures across several programs, including the Hospital Readmissions Reduction program, beginning with the FY 2027 program.
  • Shorten the Hospital RRP’s performance period from three years to two years. For example, FY 2027 HRRP penalties would be based on July 1, 2023 through June 30, 2025 performance.
  • Seek stakeholder comments in response to the Request for Information on opportunities to streamline regulations and reduce administrative burden on providers, suppliers, beneficiaries and other interest parties in the Medicare program.

The MHA continues to review the proposed rule and will provide hospitals with an estimated impact analysis in the next few weeks. The MHA encourages hospitals to review the proposed rule and submit comments to the CMS by June 10 and to notify Vickie Kunz at the MHA regarding questions or issues identified by May 27.

Virtual Training Offered Feb. 26 for FY 2022 Medicaid DSH Audit

Myers and Stauffer LC, Michigan’s contractor for the federally mandated Medicaid disproportionate share hospitals (DSH) audits, encourages hospital staff to register and participate in the upcoming Michigan-specific virtual training at 1:30 p.m. Feb. 26.

MHA members can view a pre-recorded general DSH training prior to the webinar. The pre-recorded training covers general DSH survey instructions and updates, while the Feb. 26 session will focus on Michigan-specific requirements, followed by a question-and-answer session.

Myers and Stauffer tentatively planned to distribute the initial fiscal year (FY) 2022 data request to hospitals Feb. 21, with hospitals having until March 21 to return the completed survey. All hospitals that received Medicaid DSH payments for FY 2022 are required to participate in the audit.  The MHA will share the recording and materials following the Feb. 26 webinar.

Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Nov. 18, 2024

Advocacy image tileWorkforce Bills Highlight Healthcare Legislation Advanced in the State Legislature

Several workforce bills highlighted the healthcare legislation that advanced in the state legislature during the week of Nov. 11. The Senate Appropriations Committee approved Senate Bills (SBs) 406 and 407, led by Sen. Sarah Anthony (D-Lansing). The bills provide …


MHA Board of Trustees Considers Election Impact and Association Priorities

The MHA Board of Trustees began its Nov. 13 meeting with a review of the results from the federal election and its potential impact on key association priorities, led by Carlos Jackson and Mike Goodman with Washington D.C.-based Cornerstone Government …


CMS Releases 2025 Physician Fee Schedule Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a issued a final rule to update the physician fee schedule payment system effective Jan. 1, 2025. The rule will: Reduce the PFS conversion …


MDHHS Shares 2022 Maternal and Infant Health Statistics

The Michigan Department of Health and Human Services (MDHHS) Maternal and Child Health Epidemiology Section recently led a webinar on 2022 maternal and infant health statistics for the state. Infant mortality refers to the death …


Enrollment Open for 2025 MHA Healthcare Leadership Academy

The MHA is offering its popular Healthcare Leadership Academy program in February and April 2025, with sessions at the MHA headquarters in Okemos. In partnership with Executive Core and Grand Valley State University, two power-packed …


Medical SolutionsBuilding a Culture of Retention

MHA Endorsed Business Partner Medical Solutions recently released an episode of their “Staffing Unplugged” podcast, featuring Chief Human Resources Officer Rich Thompson sharing insights on the critical role of culture in healthcare staffing. He …


Latest AHA Trustee Insights Focuses on Post-Merger Board Restructuring

The November edition of Trustee Insights, the monthly digital package from the American Hospital Association (AHA), includes CEO insights about the integration of two major health systems which resulted in stronger governance. The article explains the …


What’s Top of Mind in Rural Healthcare?

Peter Marinoff, president and CEO, Munson Healthcare’s Southern Region and MHA Small and Rural Hospital Council Chair

The following article was written by Peter Marinoff, president and CEO, Munson Healthcare’s Southern Region and MHA Small and Rural Hospital Council Chair. National Rural Health Day celebrates the remarkable efforts of hospitals, healthcare teams, …


Keckley Report

The Four Core Pillars of Trump Healthcare 2.0

“While speculation swirls around key cabinet appointments in the incoming Trump administration, much is being written about how things might change for industries and the companies that compose them. Healthcare is no exception.

Speculation about possible changes originates from media coverage, healthcare trade associations, law firms, consultancies, think tanks and academics. Their views are primarily based on Trump Healthcare 1.0 initiatives (2017-2021), presumed Trump 2.0 leverage in the U.S. Senate, House and conservative Supreme Court and a belief by the Trump-team leaders that their mandate is to lower costs for “everyday Americans” and tighten border security.

Thus, Trump Healthcare 2.0 policy changes will be extensive, leveraging legislation, executive orders, agency administrative actions, court decisions and appropriations processes to reset the U.S. health system.”

Paul Keckley, Nov. 11, 2024


News to Know

  • The Centers for Medicare & Medicaid Services (CMS) recently announced the 2025 Medicare Part A and B Premiums and Deductibles, with details available in the CMS Fact Sheet.
  • The Michigan Department of Health and Human Services has increased reimbursement rates for Behavioral Health Treatment – Applied Behavior Analysis services to improve autism treatment access for Medicaid beneficiaries.